The Red Rock Resistance

Dear Sirs:

The Nevada Outdoor Recreation Association (NORA) protests the reported efforts of the BLM to promote the development of lands, formerly held by James Hardie Gypsum and under contract to John Laing Homes for development, on Blue Diamond ridge. Newspaper accounts of the BLM's consideration of an exchange of lands on Blue Diamond ridge concern us. Such an exchange is not covered by the Stateline Resource Management Plan, the Red Rock Master Plan, and lies outside the disposal boundaries associated with the Southern Nevada Public Lands Management Act. We are also concerned that other actions, such as the issuance of permits and right-of-ways for federal lands, are being., considered that will facilitate the development of a community of 8.400 homes on the ridge adjacent to, and overlooking, the Red Rock Canyon National Conservation Area. We once again must remind the BLM of their obligation to comply with the National Environmental Policy Act for a significant federal action that will promote the development of land in a sensitive environmental area.

40 C.F.R, Parts 1500-1501, has ample references to echo the intent of Congress that the decision-making, process embodied in the National Environmental Policy Act is carried out by virtually all parts of the Federal government at an early stage (1).

We have seen no announcement by the BLM of their intentions to comply with NEPA, and no announcement of public scoping for the preparation of an EIS. We believe, given the public concern for Red Rock, that the preparation of an Environmental Impact Statement (EIS) must begin immediately.

We also are concerned that the BLM seems predisposed to pursue a land exchange to mitigate the impacts of development of the James Hardie lands when other options exist. On June 15, 1989, Ben Collins, Las Vegas District Manager, expressed his concerns about a proposed power plant on Blue Diamond hill that would impact Red Rock and its viewshed. Today, we see no public expression of concern from the BLM for the power plant, or the proposed development on Red Rock. Instead, we see a tendency by the BLM to keep a low profile and see whether these projects can be accommodated. We believe that options, such as the purchase of the James Hardie lands with monies from the Southern Nevada Public Lands Management Act, must be considered in an EIS.

We believe the development of an EIS to be a required and useful policy-making tool in allowing the public and government officials in understanding how development on Blue Diamond Ridge could impact Red Rock and the surrounding environment and on how a gypsum mining operation on lands formerly held by the public could be sold for millions for development of a golf-course community.

NORA, is registered with the IRS as a 501 c (3) organization. As a public interest organization interested in educating the public on the value of our public lands and the need to manage them wisely, we have been involved in a great many issues involving the Bureau of Land Management for decades.

NORA has been actively involved with the BLM and the Red Rock area in Nevada for decades. The Nevada Public Domain Survey (NPDS) began on January 15, 1960 at Red Rock Canyon and was completed April 21, 1964. This led to the creation of NORA in June, 1965. NORA was granted, in effect, legal standing on all future actions affecting the Red Rock Canyon area in the Las Vegas BLM District in the letter of January 17, 1967 from Eldon F. Holmes, BLM, Chief, Recreation Staff. [Attachment 1]. The NORA, in 1976, named parts of Red Rock Canyon Recreation Lands and proposed expansions of Desert View Natural Area in 1972. These named areas appeared on Las Vegas BLM District maps that were sold to the public that year. NORA has been inventorying BLM lands in the area of Red Rock since January 1960.

We have provided comments to the BLM on many occasions and on many issues involving the management of BLM lands in the Las Vegas District, the state of Nevada, and our nation. As always, we expect to be kept informed of important decisions and

actions that the BLM may take with respect to our public lands, and Red Rock is no exception..

We look forward to your response, particularly as it relates to your compliance with NEPA.

Yours very sincerely,

Charles S. Watson, Jr.
Co-Founder and Director

(1) § 1500.1 (b) NEPA procedures must insure that environmental information is available to public officials and citizens before decisions are made and before actions are taken.

§ 1500.2 (d) Encourage and facilitate public involvement in decisions which affect the quality of the human environment.

§ 1500.5 Reducing Delay
Agencies shall reduce delay by: (a) Integrating the NEPA process into early planning.

§ 1501.2 Apply NEPA early in the process
Agencies shall integrate the NEPA process with other planning at the earliest possible time to insure that
planning and decisions reflect environmental values, to avoid delays later in the process, and to head off
potential conflicts.